City Attorney Pete Holmes on Monday submitted specific recommendations to the Washington State Liquor Control Board’s draft rules for implementing Initiative 502, which Holmes championed last year as a prime sponsor of New Approach Washington.

On behalf of the City of Seattle, Holmes said in his letter, “As Washington’s largest city, with the largest number of medical marijuana facilities and strong public opinion favoring legalization, Seattle looks forward to partnering with the Board to regulate this new industry.”

Aside from supporting “the overall structure and content of the draft rules,” Holmes agreed the board should consider applicants’ prior marijuana growing and delivery convictions on an individual basis. “This approach supports I-502’s primary goal of displacing illegal competitors,” he said. “Moreover, it is well established that America’s war on marijuana results in racially disproportionate arrests and convictions -- it is encouraging to see that the Board is working to undo some of the harm caused by those past discriminatory practices.”

While agreeing with the board’s plans in large part, Holmes suggested a variety of changes to the draft rules dealing with the 1,000-foot rule, marijuana products’ availability to children, landlords of marijuana businesses, outdoor grows and waste disposal. More study is needed, he said, regarding medical marijuana, non-residential use and delivery.

Holmes also emphasized the City’s need to “share in the State’s revenue. Implementing and enforcing I-502 will be a costly venture for government at all levels, from business licensing and zoning to law enforcement and other public health and safety considerations.”

In a statement Monday, Mayor Mike McGinn said, “Seattle voters overwhelmingly approved marijuana legalization and we are working hard to implement the public’s direction in our city. The City of Seattle today formally submitted comments to the Liquor Control Board to consider during their rule-making process for I-502 implementation. Our comments are the result of my office, our law department and Council staff working together on practical and clear guidelines to help support the effective implementation of I-502 in Seattle.”

The board is expected to issue a second and final set of draft rules for comment in the next few weeks.